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Contents

Legislation
Finance (No. 2) Act 2023

Chapter 1 Introduction

  • Section 265 Introduction to domestic top-up tax
  • Section 266 Qualifying entities
  • Section 267 DTT excluded entities
  • Section 267A Securitisation companies in a group treated as not consolidated
  • Section 268 Permanent establishments
  • Section 268A Partnerships
  1. Chapter 1 · Introduction
  2. Introduction to domestic top-up tax

Section 265 | Introduction to domestic top-up tax

From legislation.gov.uk

(1)The purpose of this Part is to make provision for a qualified domestic minimum top-up tax within the meaning of the Pillar Two rules.

(2)For that purpose, this Part makes provision for a tax payable in respect of qualifying entities (that will be located in the United Kingdom) whose rate of tax (as determined in accordance with this Part) is less than 15%.

(3)The tax is to be known as “domestic top-up tax”.

(4)This Part applies (with modifications) many of the provisions of Part 3 (multinational top-up tax) for the purposes of—

(a)determining liability to domestic top-up tax, and

(b)administering domestic top-up tax.

(5)Except where the contrary appears, expressions used in this Part and in Part 3 (multinational top-up tax) have the same meaning in this Part as they have in Part 3.

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